COFI: FT/VIII/2002/Suppl.2 |
| COFI: FT/VIII/2002/Suppl.2 |
Item 4 of the Provisional Agenda |
COMMITTEE ON FISHERIES |
SUB-COMMITTEE ON FISH TRADE |
Eighth Session |
Bremen, 12-16 February 2002 |
FISH MEAL SAFETY AND TRADE |
1. During the Twenty-fourth Session of the Committee on Fisheries, held in Rome, 26 February to 2 March 2001, the Latin American and Caribbean countries expressed serious concern regarding restrictions on trade and use of fish meal for animal feed on the grounds of alleged link to the Bovine Spongiform Encephalopathy (BSE). They likewise called on FAO to monitor scientific development on this subject and the safety of fish meal in animal feeding and to report back regularly to member countries on this matter. They also noted that they did not consider trade bans in this connection to be justified. It was agreed that the subject should be placed on the agenda of the Eighth Session of the COFI Sub-Committee on Fish Trade.
2. In January 2001, the FAO Secretariat prepared an update information paper on fish meal safety for internal use and continued monitoring the scientific developments in this field. The following are excerpts of the updates prepared to date.
3. Fish meal is a ground solid product that is obtained by removing most of the water and some or most of the oil from fish or fish waste. The final fish meal product is rich in proteins, with a concentration ranging from 40% (from fish waste) to 72% (from whole fish such as herring). In comparison, soya meal is usually marketed at 45% proteins. In addition, the fish meal proteins contain all the essential amino-acids at significant concentrations.
4. The major fish meal and fish oil producing countries are Peru, Chile, the USA, Iceland, Denmark and Norway. These countries are also the main exporters, the Netherlands and Germany participate in international trade as major re-exporters. China, Japan, Canada, the UK, Germany and France are the major importers of fish meal and/or fish oil.
5. Fish meal is mainly used in the diets of poultry, pigs, fish and fur animals, which need high quality proteins. It is of special value for young animals, for example in broiler starter diets, diets for early weaned pigs and for farmed fish. In addition to proteins, fish meal contains a "growth factor" necessary in animal production.
6. Fish oil has been used for human consumption (in margarines and shortenings) or for non-edible purposes such as in varnishes, lubrication and waterproofing agents. Presently, about half of all fish oils produced go into aquafeeds. Also, fish oil has found some pharmaceutical and medicinal applications because of its high content in polyunsaturated fatty acids, constituents thought to possess anti-thrombotic activity.
7. There is no epidemiological evidence of BSE being transmitted to ruminants or other animals by fish meal. Similarly, there is no epidemiological evidence for the transmission to humans of a variant of the Creuzfeld Jacob Disease (vCJD) caused by prions that used fish or fish products as vectors.
8. Differently from ruminants, many fish are carnivorous. Commercially exploited aquatic animals are cold blooded. Also, processing whole fish or fish waste into fish meal requires a significant heat treatment (cooking in steam of the raw material and drying the pressed fish paste at a temperature of 90_C or less). These thermal processes used in fish meal production can have deleterious effects on many proteins, but this has not been studied for the BSE prion.
9. The major human safety concern regarding the use of fish meal has always been and is still Salmonella contamination. Before it is marketed, fish meal is sampled to analyse for Salmonella. If present, it can contaminate animal and dairy products, which can in turn, cause salmonellosis, a severe human food-borne infection, especially for the elderly and young children. In addition, some species of Salmonella cause damaging diseases in animal husbandry.
10. In addition, there is a growing concern about the level of some chemical pollutants, especially dioxin in fish oil. Recent reports indicate that fish meal and fish oil of European origin have dioxin levels up to eight times as high as similar products from non-industrial regions, like the waters off Peru and Chile.
11. Several consultations were held at the European Union Commission during late November and early December 2000 to see whether the EU should apply an outright ban on the feeding of animal proteins (including fish meal) to all animals if the controls on these proteins are not adequate. Finally the EU passed a Council Decision (2000/776 4 December 2000), which states that: "as a precautionary measure, it is appropriate to prohibit on a temporary basis the use of animal protein in animal feed, pending a total re-evaluation of the implementation of Community legislation in Member States. As this prohibition could have environmental implications if not controlled properly, it is necessary to ensure that animal waste is collected, transported, processed, stored and disposed of in a safe manner. This prohibition shall not apply to the feeding of fish meal to animals other than ruminants".
12. The EU Decision entered into force on 1 January 2001 and is always applied. In addition, the feeding of fish meal to animals other than ruminants, can take place only in accordance with conditions pertaining to requirements for fish meal plants, transportation, storage, labelling and traceability of fish meal consignments from production to utilization (EU Decision 2001/9/EC of 29 December 2000).
13. The banning of the use of fish meal for feeding ruminants does not have a significant impact on the international fish market. Indeed, the loss of the EU market for fish meal in ruminant diets was estimated at only 70 000 tonnes. To the contrary, banning the feeding of other animal proteins to all animals has created a potential market of about 2 million tonnes to replace the banned animal proteins. There was concern that this may increase dramatically the risk for adulteration of fish meal with other mammalian meat and bonemeal (MMBM). The latter issue is exacerbated by the fact that reliable routine techniques to detect adulteration, are still under scrutiny.
14. In December 2001, EU Commission representatives met with representatives of the fish meal producers and European traders and stressed that the temporary restrictions on the use of fish meal in ruminant diets has been imposed as a result of the EU Commission's needs to ensure that ruminant feed no longer contains MMBM. With the present EU approved analytical method (i.e. microscopy) which relies on identifying bone fragments, the presence of fish meal in ruminant feed makes analytical detection of MMBM more difficult. The Commission representatives made it clear that two requirements were necessary before the EU Commission will formulate proposals for lifting the temporary ban on fish meal used in ruminant diets:
15. The proposed EU regulation laying down the health rules concerning animal by-products not intended for human consumption is mainly a consolidation of previous Directives concerning the production and distribution of fish meal and should not present the fish meal industry with any major problems. However, and in view of the research currently undertaken in Europe, it is not expected that any analytical method will be approved by the EU for the purpose of detecting land animal proteins before June 2003.
16. In addition, considering the matter of different contaminants in feed and feed ingredients, the EU, by 1 July 2002, will introduce legislation to set maximum levels of dioxins as follows: 6.0 ng/kg of fish oil, 1.25 ng/kg of fish meal, 2.25 ng/kg of compounded fish feeds. It is expected that the Commission will review these levels before December 2006 and probably include PCBs.
17. There is no epidemiological evidence of BSE being transmitted to ruminants or other animals by fish meal. Similarly, there is no epidemiological evidence for the transmission to humans of a variant of the Creuzfeld Jacob Disease (vCJD) caused by prions that used fish or fish products as vectors.
18. The major human safety concern regarding the use of fish meal is Salmonella contamination. In addition, there is a growing concern about the level of some chemical pollutants, especially dioxin in fish oil. It is important to stress that one can question the fact that the EU allows human consumption of fish but does not allow animals to consume fish meal made from whole fish or from fish waste.
19. The present EU ban on the utilization of fish meal for feeding ruminants is likely to continue because of the EU concern regarding the risk for adulteration of fish meal with other MMBM. The development of a validated method able to detect the presence of MMBM in ruminant feeds even in the presence of fish meal in the same feed is not foreseen before June 2003.
20. The FAO Fisheries Department will continue monitoring closely the scientific development in BSE and dioxins, as part of a broader risk analysis-based approach to the safety of fish and fishery products for human consumption. But the limited resources are presently devoted to field activities addressing the known biological hazards associated with fish consumption and impeding fish trade, especially from developing countries.
21. The Sub-Committee should discuss the information received and indicate whether further investigations in the matter are essential. Should this be the case, their relevant recommendations to COFI will be required.